Murray v. The Queen, 2014 DTC 1085 [at at 3111], 2013 TCC 253 -- summary under Section 87

The taxpayer was a status Indian living off-reserve. He owned two business corporations which were headquartered on the reserve but which sold office supplies and office furniture primarily to Ottawa-region federal departments using stores located off-reserve. The corporations paid him management fees equal to their earnings. D'Auray J found that these fees were not exempt under s. 87. The management fees were more consistent with business income than employment income, and in the case of active business income "the place where the income is generated is an important connecting factor" (para. 104). The taxpayer's management services were provided predominantly off the reserve, where the taxpayer spent most of his time. Other connecting factors also favoured a finding that the management services income was earned off-reserve.